ACAA Regulation on the Transport of Service Animals

On January 22, 2020 The U.S. Department of Transportation announced that it is seeking public comment on proposed amendments to its Air Carrier Access Act (ACAA) regulation on the transport of service animals.

The following chart courtesy of HABRI visually provides an excellent overview clarifying the differences between service animals, emotional support animals, therapy animals and pets.  Scroll past the chart for a brief overview of proposed amendments and additional resources.

The U.S. Department of Transportation is proposing to ban all service animals except dogs aboard U.S. flights. Airlines would also no longer have to accommodate emotional support animals. Airlines could ban emotional-support animals including untrained dogs, cats and more exotic companions such as pigs, pheasants, rabbits and snakes.

In a statement on their website they state “the department recognizes the integral role that service animals play in the lives of many individuals with disabilities and wants to ensure that individuals with disabilities can continue using their service animals while also reducing the likelihood that passengers wishing to travel with their pets on aircraft will be able to falsely claim their pets are service animals.”

In limiting the options to dogs, the department states that its proposed definition aligns with the one used by the Department of Justice and the Americans With Disabilities Act*.

This is a very complicated and complex issue. We encourage you to read the regulations and respond to them with your comments.  The proposed amendments can be found at https://www.regulations.gov/docket?D=DOT-OST-2018-0068

Comments must be received by April 6, 2020.

https://www.transportation.gov/briefing-room/us-department-transportation-seeks-comment-proposed-amendments-regulation-service

* https://www.ada.gov/regs2010/service_animal_qa.html#exc

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